Yes

ID sylw: 107506

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

Land ownership – single land owner
Site capacity – Up to 690 dwellings with primary school land option, all on Davidsons controlled land.
On site infrastructure delivery – land reserved for primary school, blue and green infrastructure including community orchards/food production, extensive land parcel set aside solely for biodiversity net gain, linkages to connect in with existing non car travel routes in urban area, linkages to Welcombe Hills Country Park, café/tourism hub and visitor parking to serve Welcombe Hills Country Park, 50% affordable housing, public open space in a range of typologies.
Off site infrastructure delivery – layout to ‘forward face’ and integrate with Welcombe Hills Country Park, junction improvements as determined by strategic transport modelling and site specific Transport Assessment, travel plans and a package of sustainable transport improvements, education contributions, health contributions, integration with wider biodiversity net gain site.

No

ID sylw: 107507

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

The policy refers to meeting housing requirements as expressed in the HEDNA, with sufficient flexibility to accommodate the housing requirements as set out in the 2024 Standard Method. We have some sympathy for the Council; at the time of preparing the Preferred Options SWLP the revisions to the NPPF, and associated update to the Standard Method, were in draft form only and subject to change. However, with the revisions to the NPPF and Standard Method now finalised the SWLP should commit to the Standard Method requirement and make no reference to the HEDNA.
Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62, whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF paragraph 69.

Yes

ID sylw: 107508

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We support the approach set out in Policy Direction 3. Built Up Area Boundaries should be reviewed to take account of committed development which has occurred since the adoption of the Core Strategy, and also to take account of new allocations proposed through the SWLP to ensure that ‘countryside’ policies do not apply to allocated sites.

Yes

ID sylw: 107509

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

Previous commitments, such as theMemorandum of Understanding (MoU) between Coventry and Warwickshire authorities, have resulted in Stratford-on-Avon and North Warwickshire allocating 2,880 dwellings to assist Coventry. However, these allocations must be revisited within the South Warwickshire Local Plan (SWLP) to ensure a continued and strategic approach to housing provision that aligns with the latest evidence base.
The SWLP must also recognise its strategic position within both the Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA. Stratford-on-Avon has historically contributed to both HMAs, with allocations of 2,720 dwellings for Greater Birmingham and Black Country and 2,880 dwellings for Coventry and Warwickshire. As the plan extends to 2050, it must acknowledge the ongoing cross-boundary pressures and proactively accommodate a proportionate share of the unmet housing need. Deferring this responsibility to development management decisions or reserve sites would undermine the plan-led approach required by the National Planning Policy Framework (NPPF). Instead, a forward-looking policy framework should be established, ensuring that housing allocations comprehensively address regional demands while balancing infrastructure capacity and sustainability objectives.
Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic, economic, and migration trends influencing South Warwickshire’s housing market.
The SWLP will need to make a contribution by way of a duty to co-operate and accommodate unmet housing needs arising from outside the SWLP plan area. It is imperative that this is planned for now, having regard to NPPF paragraph 69.

No

ID sylw: 107510

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations. This is not a matter to be deferred to the Publication Consultation (this being the final consultation prior to the SWLP being submitted for examination).
We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site promoters so as to bring forward genuinely deliverable site options.

Yes

ID sylw: 107511

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We endorse the safeguarding at the A46/Bishopton roundabout, which is a long-standing commitment and remains a key part of the strategic road network which the Councils and National Highways are seeking to improve.
Co-locating new development with safeguarded land/strategic network improvements has significant advantages. New development can assist in assimilating infrastructure upgrades into the receiving landscape, by designing in buffers and landscape strategies avoiding the landscape and visual effects of hard engineered proposals. Furthermore, co-locating new development with network upgrades allows for a proportion of the upgrade costs to be borne by new development, which is fiscally prudent and in the public interest.

Other

ID sylw: 107512

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We support the Council’s approach to undertaking a Green Belt review as an integral part of the evidence base underpinning the SWLP.
We do however object to any sequential approach to Green Belt release, where this seeks to allocate non-Green Belt sites before considering Green Belt release. This is a wholly inappropriate approach, it does not in accordance with the NPPF which has no such sequential approach to Green Belt release, and risks bringing forward a plan which is not founded on robust broader sustainability principles. For example, applying a sequential approach would close off significant parts of the main towns of Stratford, Warwick, Leamington Spa and Kenilworth. It would also make addressing the duty to co-operate far more difficult since a sequential approach would effectively push any housing requirements meeting the two HMA’s further south away from the HMA areas which housing is intended to serve.

No

ID sylw: 107513

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban quality, some of the Council’s highest valued urban areas deliver densities at what might be considered to be very high. By way of worked example, a maisonette doubles the density of a building over a traditional house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish what each spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means that site viability, and thus deliverability, cannot be established with promoters since the infrastructure requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Yes

ID sylw: 107514

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We broadly support the requirements to make efficient use of brownfield land. Recycling previously developed land can (though not always) achieve a series of sustainability objectives.
However, the scale of housing required in the plan area – even by the HEDNA evidence, which is significantly below the Standard Method and before adding in the duty to co-operate – is such that brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in the plan area.
Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward brownfield sites ahead of green field opportunities. Setting aside that broader sustainability objectives should be applied (for example, a Green Belt site on the edge of Stratford town performs significantly better than an isolated brownfield site in National Landscape) the NPPF contains no such sequential approach to previously developed land. The sequential approach to brownfield development was founded in PPS3 and PPG3 before it, and was expressly removed from the NPPF in 2012 and has not been re-introduced in any of the revisions to the NPPF since.

Yes

ID sylw: 107515

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We broadly support the principle that the SWLP should deliver a range of housing of differing sizes, types and tenures.
However, housing mix policies are often drafted in a rigid manner, with little opportunity for flexibility of application to reflect site specific circumstances and market demand.
For example, a town centre site is rarely able to deliver family housing, and nor need it given that town centre living is a housing market in and of itself. Conversely, with town centre sites delivering smaller housing types those sites in edge of settlement locations should deliver larger family type housing. Put simply, the policy should be drafted to allow for a range of housing types and tenures across the plan area, rather than across individual sites. The Councils could keep an up-to-date annual monitor to establish in each reporting year how the delivery is performing against the objectives of Policy Direction 10.
Insofar as housing tenures, the NPPF sets out what is now considered to be affordable tenures in meeting affordable housing need. We strongly support first homes and other forms of discount from open market level, which provides for ‘second tier’ affordable provision delivered by the private sector without the need for any public intervention, which are more deliverable given the lack of appetite from registered providers to purchase built S106 homes, as has been widely experienced nationally since the interest rate rises of 2022.